California, United States of America
The following excerpt is from People v. Allen, C074260 (Cal. App. 2019):
distinguished. For example, in People v. Roldan (2012) 205 Cal.App.4th 969, the prosecution knew, but did not disclose to the defense or take a single precautionary step, that a material witness would be deported at the conclusion of the preliminary hearing. The prosecution did not impress on the witness the importance of staying in touch with investigators; nor did it seek a section 1332 material witness hold. Needless to say, the prosecution was well aware the material witness would be unavailable for trial and yet it sat idle.